In today’s delivery world, balancing customer service demands with company needs such as controlling costs and filing IFTA paperwork is a daily challenge. Many short haul operations can now add the ELD Mandate to that list, but there is a lot of confusion out there as to who really needs to comply.
As defined in the FMCSA Hours of Service Regulations, in order to meet the definition for short haul, you must:
- Start and return to the same location within 12 hours
- Drive no more than 11 hours
- Have ten consecutive hours off between shifts
- Maintain your time clock function
- Not have paper logs more than eight times in 30 days
If fleets break even one of these, they are no longer exempt. If a driver breaks one of these items, he or she has to take a 30-minute break before continuing to drive. Then there are the air miles. Draw a line from the distribution center out 100 miles for CDLs and 150 miles for non-CDLs. It’s all a lot to keep track of and hard for fleets to know when they should be keeping logs or purchasing ELDs.
To help, here are some common short haul questions and answers.
Do my line haul drivers need to have ELDs?
That depends on your distance between distribution centers. Many line haul distribution centers could be more than 100 miles away and many times their drivers drive a couple hundred miles to the next distribution center to deliver product.
In those cases, you’re definitely not qualifying for short haul – you’re a line haul or long haul driver. That driver would need to keep a record of duty status and have an ELD in the truck. That may be the only ones who need it in your fleet if complying with short-haul rules. But if you have an ELD, it’s an insurance policy — when you do break it, the ELD will catch it and eliminate the paperwork of keeping a paper log.
What happens when you have drivers who work for more than one company?
If the driver is required to keep a record of duty status, then that driver has to have seven days plus current with them readily available in the vehicle. When you have to add more drivers during a seasonal swing, for example, it doesn’t matter if your driver drove or just worked somewhere else — they have to be able to come up with the on-duty time that they had in those previous days.
You have to account for your 60 or 70 hour week. If the driver only drives for you for three days but they worked elsewhere — driving or not driving — you have to account for the on-duty time so that you can fulfill those seven days plus current in that vehicle. Those drivers can show their driving time in the form of a PDF file or an affidavit statement identifying where they worked and the number of hours put in.
If I have a short haul driver who does not require an ELD (because he’s always under 12 hours and under the air mile limit, as well as returns to starting location), what if something happens on the route and one day he exceeds but doesn’t have an ELD?
It’s okay if you do that for one day. You can break one of the criteria for one day and keep paper logs. If you’re on a system and invoke the short haul ruleset, it would automatically keep an electronic log for you once you break one of those criteria. But if you don’t have an ELD in your vehicle and only break for one day, you don’t need an ELD.
The way the mandate is written, there is a 30 rolling calendar day. If you break your short-haul more than eight times in those rolling 30 days, then you’d be required to keep and ELD until you get back to that lower number. If you’re just breaking once or twice a week or five times a month, you have to keep paper logs. But you have to keep a detailed log of the days you’re breaking the rule.
If only a portion of my routes are outside of the short-haul air mile rules, does that affect the short haul rules for my local route?
No. Let’s say Vehicle A is on Route #1 and Route #1 gets drivers back within 12 hours and keeps them in the 100-mile radius, then you are fine. Keep in mind: With short haul, it is difficult to drive more than 11 hours because of stops and pickups.
In addition to CDL trucks, we have non-CDL vans. Do they also need to have ELDs in them?
No. As long as you can adhere on a regular basis (per ELD Mandate: Don’t break those rule sets any more than eight times in 30 days). If they qualify for non-CDL short haul, then they are not required to have an ELD. But look at what your profile has been. Make sure those non-CDL drivers aren’t breaking the rules. This may start to exceed the costs of putting in an ELD.
Don’t forget: If you break the rule more than eight times in 30 days, you could be required to have that ELD in the vehicle for three days until you until you get back to lower number — or a couple weeks. Take a good look at how many times you’re breaking those rule sets.
For more information on the ELD Mandate and short haul, sign up for Fleet Owner’s webinar. FMCSA Director Joe DeLorenzo will go over the rule and representatives from Preferred Meals and Lindenmeyr Munroe will give a fleet perspective. Register here.